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HMRC internal manual

Money Laundering Regulations: Registration

High Value Dealers (HVDs): Meaning of "goods"

This has its normal everyday meaning.

If, in the course of providing a service, a business supplies goods which are ancillary to that service, they will not be dealing in goods.

You should look at all the circumstances of the case when deciding whether a transaction, involving both goods and services, amounts to dealing in goods. In general, we consider businesses to be dealing in goods if the open market value of the goods represents €10,000 or more, of the amount they charge their customer.

For example, if a business processes goods and enhances their value (for example, a jeweller who sets a stone in a ring), that business is an HVD if they sell those goods for cash and the amount received is equivalent to €10,000 or more.

However, if a business provides both goods and services (for example the sale of a car with an extended warranty or vehicle insurance) then the value of the service i.e. the extended warranty or vehicle insurance, will not be included as part of the cash transaction.